ML20203P573

Ack Receipt of Transmitting Two Changes to QA Program.Changes Acceptable as Listed

ML20203P573
Person / Time
Site:	Pilgrim
Issue date:	04/24/1986
From:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Harrington W BOSTON EDISON CO.
References
NUDOCS 8605070478
Download: ML20203P573 (2)

Text

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APR 2 41985 Docket No. 50-293 Boston Edison Company M/C Nuclear ATTN: Mr. William D. Harrington

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Senior Vice President, Nuclear e

800 Boylston Street Boston, Massachusetts 02199

Dear Mr. Harrington:

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Subject:

Quality Assurance (QA) Program Description Change Reviiw

Reference:

BECo Letter No. 86-17, from W. D. Harrington to T.

E'. Murley, dated February 21, 1986 We have received the referenced letter that transmitted two changes to the Boston Edison QA Program in ac.ordance with 10 CFR 50.54(a).

Based on our review of the changes and an April 8, 1986 telephone conversation between Dr. P. K. Eapen and Mr. G. Napuda of our staff with your Mr. F. Schellenger we find these changes acceptable as discussed below:

f Change 1: Section 2.5.6, Paragraph 4 A more limiting change was instituted by your staff in Revision 19, dated August 12, 1985, subsequent to NRC approval of Revision 18 dated May 22, 1985.

This interim change required the QA manager to escalate differences of opinion between QA and other department personnel to the vice president level, if an acceptable resolution is not obtained within five days.

Your staff found this five day limit to be impractical for all differences of opinion and requested the present change to go back to the wording in Revision 18.

The NRC staff finds this request acceptable since the proposed revision is consistent with the position previously approved by the NRC.

Change 2: Section 18.4.6 Your staff desires to inpose a definite time limit for escalating the differ-ences of opinion between QA and other personnel to the vice president level, when these differences stem from Deficiency Reports.

To meet this intent, you requested an amendment to Section 18.4.6 to require the QA manager to escalate such differences of opinion to the vice president' level if an acceptable resolution is not obtained within fifteen day's.

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The NRC staff finds this request also acceptable as,the proposed revision is an improvement over a position previously approved by the NRC.

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The effectiveness of your QA Program implementation will continue to be the subject of future routine NRC inspection.

If you have any further questions in this regard, please contact Dr. P. K.

Eapen, Chief, Quality Assurance Section at 215-337-5150.

Sincerely, e2%'~-'.rfr- >ryi Ste rt D. Ebneter, Director Division of Reactor Safety cc w/ encl:

L. Oxsen, Vice President, Nuclear Operations C. J. Mathis, Station Manager Joanne Shotwell, Assistant Attorney General Paul Levy, Chairman, Department of Public Utilities W. J. Nolan, Chairman, Plymouth Board of Selectmen Plymouth Civil Defense Director Senator Edward P. Kirby Public Document Room (PDR) local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Commonwealth of Massachusetts (2)

QUAB IE bec w/ encl:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

Section Chief, DRP S. Ebneter, DRS G. Napuda, DRS P. Eapen, DRS L. Bettenhausen, DRS L. Tripp, DRP DPR Licensing (w/ concurrences)

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g BOUTON, M ASSACHUSETTE O2199 WILLIAM O. HARRINGTON SEmeen wees resesses, NS$bSAS February 21, 1986 BEco Letter No.86-017 Dr. Thomas E. Murley Regional Administrator U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 License No. DPR-35 Docket No. 50-293 t

Reauest of ADDroval for QA Program Description t

Changes that Reduce Constitments

Reference:

(a) Letter from W.D. Harrington, Senior Vice President (BEco) to the NRC Regional Administrator (Region I), dated July 7, 1985;

Subject:

Annual Report of Changes to the Boston Edison QA Program Description (BECo Ref. 2.85.121)

Enclosure:

(A) Proposed QA Program Description Changes

Dear Dr. Murley:

Pursuant to 10CFR50.54(a), Boston Edison hereby submits for approval two proposed changes to the QA Program Description. These changes have been evaluated as reducing constitments which were added since the submittal of Reference (a).

Enclosure (A) identifies the changes, lists reasons for the changes, and provides the bases for BEco's evaluation as continuing to satisfy 10CFR50, Appendix 8.

These changes will not be implemented until approved by your office.

Please inform us of the results of your review at your earliest convenience.

If you have any questions or concerns, don't hesitate to contact us.

Very truly yours, i

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ENCLOSURE (A)

PROPOSED OA PROGRAM DESCRIPTION CHANGES CHANGE 1 - Current Wordina (Section 2.5.6. ParagraDh 4)

If a difference of opinion arises between Quality Assurance personnel and those of another department, resolution is first attempted by the Quality Assurance Manager and the other cognizant manager.

If within five working days a solution acceptable to the QA Manager cannot be obtained, the matter shall be promptly referred by the QA Manager to the Vice Presidents for resolution.

If a resolution acceptable to the QA Manager is not obtained after it has been referred to the Vice Presidents, the matter shall be promptly referred by the QA Manager to the Senior Vice President (Nuclear) and, if necessary, to the President, for resolution.

Chanae In the fourth paragraph of 2.5.6, second sentence, remove the words "within five working days."

Reason for Change The five day limit was found to be impractical when applied to all situations, so a 15 day time period for Deficiency Report resolution is proposed instead in Change 2 below.

ADDendiX 8 ComDliance The change does not limit persons and organizations performing quality assurance functions from having sufficient authority and organizational freedom to identify quality problems, to initiate, reconnend, or provide solutions, to verify implementation of solutions, or to report findings to appropriate levels of management.

CHANGE 2 - Current Wordina (Section 18.4.6)

Should Quality Assurance not concur with actual / proposed corrective action, and be unable to obtain satisfactory resolution directly with the responsible manager, a formal request for a second response shall be forwarded to the appropriate Vice President.

The Quality Assurance Manager may, if deemed appropriate, implement the requirements of Paragraph 2.5.6 of this manual.

Change Revise the last sentence of Paragraph 18.4.6 and add a new sentence, as follows:

Page 1 of 2

<r' Enclosure (A)

... The Quality Assurance Manager may, if he deems it appropriate, implement the requirements of Paragraph 2.5.6 of this manual.

In such cases involving DR resolution, the QA Manager shall refer the matter to the Vice Presidents if a resolution acceptable to him cannot be obtained within 15 days."

Reason for Change This proposed revision, in conjunction with Change 1 above, forms a more workable system for resolution of differences of opinion.

Appendix B Compliance This change does not limit the independence of the QA function or disrupt management reporting systems.

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